News & Analysis as of

Corporate Transparency Act Stays Filing Deadlines

Bricker Graydon LLP

The CTA is Back in Play, with a Slight Extension

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CTA Update – On Tuesday, February 18, 2025, the US District Court for the Eastern District of Texas stayed its order from January 7, 2025, which provided a nationwide injunction on the CTA’s enforcement....more

Dorsey & Whitney LLP

FinCEN Confirms New CTA Filing Deadline - But Congress Looks to Push Deadlines For Some Reporting Entities to 2026

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On February 18, 2025, in a widely expected decision, the Eastern District of Texas, in the case of Smith v. United States Dep't of the Treasury, 2025 WL 41924 (E.D. Tex.), and following the decision of the U.S. Supreme Court...more

Parker Poe Adams & Bernstein LLP

Corporate Transparency Act Reporting Requirements Are Back: New March 21 Deadline

In the latest twist involving the Corporate Transparency Act (CTA), the only nationwide injunction still in effect that barred enforcement of the CTA’s filing deadlines (Smith vs. U.S. Department of the Treasury) was stayed...more

BakerHostetler

CTA Back in Effect; New Reporting Deadline of March 21

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On Feb. 17, the Texas federal district court in Smith v. U.S. Department of the Treasury granted the government’s motion for an immediate stay pending appeal of the nationwide order staying the effective date of the final...more

Pullman & Comley, LLC

The Corporate Transparency Act is Back (For Now): Texas Court Lifts Final Nationwide Injunction Against the CTA

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The Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting requirements are back in effect. On Monday, February 18, 2025, a federal district court in Texas granted a stay of the nationwide...more

Bowditch & Dewey

Corporate Transparency Act – Supreme Court Allows Enforcement of the Corporate Transparency Act (CTA)

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On January 23, 2025, the Supreme Court stayed the nationwide injunction that was put in place by the Fifth Circuit barring enforcement of the CTA. This decision allows the Financial Crimes Enforcement Network (“FinCEN”) to...more

Ruder Ware

The CTA Journey – It Goes On and On and On

Ruder Ware on

The Corporate Transparency Act (“CTA”) has been on a journey this past month with a whirlwind of court rulings: halted by a federal district court, reinstated by the Fifth Circuit’s motions panel, had its reporting deadlines...more

Sheppard Mullin Richter & Hampton LLP

Fifth Circuit Court of Appeals Vacates Its Own Stay Rendering the Corporate Transparency Act Unenforceable . . . Again

On December 26, 2024, in Texas Top Cop Shop, Inc. v. Garland, No. 24-40792, 2024 WL 5224138 (5th Cir. Dec. 26, 2024), a merits panel of the United States Court of Appeals for the Fifth Circuit issued an order vacating the...more

Sullivan & Worcester

Breaking: Corporate Transparency Act on Hold Again

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Late on December 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reversed its own decision from earlier in the week, reinstating the nationwide preliminary injunction preventing the enforcement of the Corporate...more

Jaburg Wilk

CTA Beneficial Ownership Reporting Requirements Reinstated – With Deadline Extensions

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The Fifth Circuit has removed the nationwide injunction concerning Corporate Transparency Act reporting. The Fifth Circuit’s decision overrides the earlier nationwide relief granted by the district court. Litigation will...more

Lerman Senter PLLC

Fifth Circuit Reinstates Stay on Ownership Reporting - Deadline Lifted

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On December 26, 2024, the Fifth Circuit reinstated a stay of the Corporate Transparency Act’s requirement that businesses must file Beneficial Ownership Information reports. Accordingly, there is at present no obligation to...more

UB Greensfelder LLP

Fifth Circuit Court of Appeals Reinstates Nationwide Injunction Blocking Enforcement of the Corporate Transparency Act

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On December 26, 2024, the Fifth Circuit Court of Appeals reinstated the nationwide preliminary injunction blocking enforcement of the Corporate Transparency Act (CTA). This decision was made to "preserve the constitutional...more

Womble Bond Dickinson

Update: CTA Filing Requirements Are "On" - Compliance Required by January 13, 2025 (for most reporting companies)

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On December 23, 2024, the Court of Appeals for the Fifth Circuit stayed the nationwide injunction enjoining the U.S. government from enforcing the Corporate Transparency Act (the “CTA”) and the corresponding reporting...more

BCLP

To File, or Not to File: the Fifth Circuit’s Evolving Treatment of the Corporate Transparency Act

BCLP on

The U.S. Court of Appeals for the Fifth Circuit reinstated and then subsequently suspended the reporting requirements under the Corporate Transparency Act (the “CTA”) over the course of the last week by staying the original...more

Womble Bond Dickinson

CTA UPDATE: No Action Needed Yet - Mandatory CTA Filings are “OFF” For Now

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On December 26, 2024, the Court of Appeals for the Fifth Circuit VACATED a ruling early this week to stay the nationwide injunction enjoining the U.S. government from enforcing the Corporate Transparency Act (the “CTA”) and...more

Epstein Becker & Green

Enforcement of CTA Halted Yet Again After Federal Court Reverses Course and Reinstates Nationwide Injunction

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On December 26, 2024, in a surprising move, the U.S. Court of Appeals for the Fifth Circuit issued a decision reinstating the nationwide injunction against enforcement of reporting requirements for beneficial ownership...more

Winstead PC

News Alert: Fifth Circuit Reinstates Beneficial Ownership Reporting Injunction

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Late on December 26, 2024, a panel of the Fifth Circuit ordered the injunction back into effect. Timing is uncertain for any oral arguments or other court rulings....more

Parker Poe Adams & Bernstein LLP

Corporate Transparency Act Filings Are Back on Hold

In an unusual turn of events, the Fifth Circuit Court of Appeals has reversed itself and put the Corporate Transparency Act (CTA) back on hold....more

Dorsey & Whitney LLP

CTA Compliance Paused Yet Again - Federal Appeals Court Reinstates Temporary Nationwide Injunction

Dorsey & Whitney LLP on

As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the Corporate Transparency Act (“CTA”). Texas Top Cop...more

Kaufman & Canoles

The Corporate Transparency Act Filing Deadline Stayed Once Again

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On Thursday, December 26, 2024, the United States Court of Appeals for the Fifth Circuit reinstated the nationwide injunction staying the CTA filing deadline....more

Eversheds Sutherland (US) LLP

Fifth Circuit changes course—CTA preliminary injunction reinstated

On December 26, 2024, the US Court of Appeals for the Fifth Circuit changed course, effectively reinstating the preliminary injunction enjoining enforcement of the Corporate Transparency Act (CTA)....more

Perkins Coie

Corporate Transparency Act: Court Swiftly Reimposes Injunction Against Enforcement

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As reported in our recent Update, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction against enforcement of the beneficial ownership information reporting requirements of the...more

Benesch

On Hold AGAIN - CTA Preliminary Injunction Reinstated

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As we previously reported, on December 3, 2024, the U.S. District Court for the Eastern District of Texas issued a nationwide preliminary injunction blocking the U.S. Department of Treasury from enforcing the Corporate...more

Miller Canfield

Fifth Circuit Reinstates Texas Federal District Court’s Nationwide Preliminary Injunction and Stay of the Corporate Transparency...

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Late in the day on December 26, 2024, the United States Court of Appeals for the Fifth Circuit reinstated a nationwide injunction staying enforcement of the Corporate Transparency Act (CTA) and its reporting rules and...more

Holland & Knight LLP

Corporate Transparency Act: Nationwide Injunction in Place Again; All Filing Deadlines Suspended

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In a continuing series of dizzying judicial actions, the U.S. Court of Appeals for the Fifth Circuit on Dec. 26, 2024, vacated the stay and reinstated the nationwide preliminary injunction enjoining enforcement of the...more

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